RECEIVED

CLERK’S OFFICE

MAR

-92005

STATE OF ILLINOIS

Pollution Control Board

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

March

7, 2005

KIMBLE GLASS, INC.

)

)

Petitioner,

)

)

V.

)

)

IEPA-05-55

ILLINOIS ENVIRONMENTAL PROTECTION

)

AGENCY,

)

(Provisional

)

Variance- Air)

Respondent.

)

)

Re: Request for Provisional Variance

for Furnace B;

Electrostatic Precipitator

Bypass

On February

16,

2005, the Illinois

EPA received

from

Kimble

Glass,

Inc.

(“Kimble”) a

request

for provisional

variance

to

allow

the

bypass

of the

electrostatic

precipitator

(“ESP”)

controlling particulate matter emissions from

glass-melting furnace B with oxy-

fuel melter (“furnace

B”) while repairs are being made to the ESP at the Chicago Heights

facility.

The request was accepted for review pursuant to the requirements ofthe Illinois

Environmental

Protection Act (“Act”) and the applicable regulations.

The

Illinois

EPA has evaluated the request pursuant

to

the requirements of Sections

35,

36,

and

37

of the

Act

and

35

Iii.

Adm.

Code

Part

180.

The

Illinois

EPA is

granting

Kimble’s request for provisional variance as the source has demonstrated that an arbitrary

and unreasonable hardship will result in the event of a denial.

Specifically, Kimble seeks

provisional

variance

from

condition

7.5.5(b)

of

CAAPP

permit

number

95090043

(requiring operation ofthe ESP at all times

during operation of furnace B) and

the pound

per hour particulate matter (“PM”)

limit in

condition

7.5.6(a)

of CAAIPP permit

number

95090043

and 35111. Adm.

Code 212.321,Tor a period not to exceed 72 hours.

Kimble estimates

that

PM

emissions

during

the 72-hour repair period will approximate

6.7 pounds per hour, with

an

estimated total

emission of482 pounds of PM.

Kimble

is

limited by permit to 6.04 tons ofPM per year from furnace B.

The emissions

resulting

---

from the bypass ofthe ESP are not likely to exceed

the annual PM limit given the limited

duration ofemergency provisional variance.

The

Illinois

EPA

is

granting Kimble’s request for a provisional

variance subject to

the

following conditions:

1.

Upon

receipt of this

letter, Kimble

shall notify

the

Illinois

EPA

of the

specific

72 hours during which the repairs to the ESP will commence and

be completed.

2.

Kimble

shall complete

repairs on ESP within

30

days of the issuance of

the provisional variance.

3.

While repairing/bypassing the ESP, Kimble

shall take all reasonable steps

to minimize PM emissions including:

a.

Reducing the input ofraw materials by at least 25 percent.

b.

Increasing

cullet

input

to

at

least

50

percent

(currently

35

to

40

percent).

4.

Within

45

days of completing the repairs, Kimble

shall send the

Illinois

EPA

a

report

detailing

the

cause

of

the

malfunction

of

and

repairs

completed

on

the

ESP, actions

taken

by

Kimble

to

minimize

emissions

during

the bypass/repair

event, and

details

on

the process and

emissions

during the bypass/repair event.

5.

Upon

completion

of the

repairs,

Kimble

shall

conduct

a

stack

test

of

furnace

B

and

the

ESP

to

demonstrate

compliance

with

all

applicable

emission limits.

Kimble shall adhere to

the following test guidelines:

a.

Testing

shall

be

conducted,

documented,

and

reported

by

an

independent

testing

service

in

accordance

with

appropriate USEPA

Methods and Procedures

and

an approved Stack Test Protocol. Copies

of the proposed test protocol

shall be

submitted

at least 30

days prior

to

the

scheduled

test

date.

However,

the

Illinois

EPA

can

accept

a

shorter

notification

period

if

it

does not

interfere with

Illinois

EPA

representatives’ ability to witness the test.

b.

Final

confirmation

of the

exact

date

and

time

of the

test

shall

be

provided at least five

(5)

days prior to the test date.

c.

Testing

shall

be

conducted

under

conditions

representative

of

maximum

process

operating

rates

and

prior

to

making

any

---

modification

to

the existing

source

equipment, control

equipment,

or

stacks.

d.

The

final

report

for

the

test

shall

be

submitted

within

45

days

of

completion oftesting.

e.

Reports and notifications described above shall be submitted to:

i.

Illinois

EPA

—

Compliance and Enforcement Section

Illinois

Environmental Protection Agency

Bureau ofAir

Compliance and Enforcement Section (MC 40)

P.O.

Box

19276

Springfield, Illinois

62796-9276

ii.

Illinois EPA

—

Air Regional Field Office

Illinois Environmental Protection Agency

Division ofAir Pollution

Control

9511

West Harrison Street

Des Plaines, Illinois

60016

iii.

Illinois EPA

—

Source Monitoring Unit

Illinois Environmental Protection Agency

Bureau ofAir, Source Monitoring Unit

Attn: Kevin Mattison

9511

West Harrison Street

Des Plaines, Illinois

60016

6.

Kimble

Glass, Inc.

shall sign a certificate ofacceptance of this provisional

variance and

forward that

certificate to

the Compliance and

Enforcement

Section

at the

address indicated above within ten days of the date ofthis

order.

The certification should take the following form:

I (We)

,

hereby accept

and agree to be

bound by all terms and

conditions ofthe provisional variance

granted by the Agency in

_____________

dated

Petitioner

Authorized Agent

---

Title

Date

Sincerel

William D. Inger

Acting ChiefCounsel

cc:

IPCB, Clerk

Roshna Bala, Sidley and Austin

---

J.D.

#~

Name:

Prop.

Category;

February

15,

2005

K~mb~e

CI~ss,

nc.

53/

C~ystai

Avenue

\1nel~nd,

NJ

08360

James B. Rocco

V~’

0”~’ht

DAliua1~1

Manager Environmental Services

Telephone

856.794-7125

Ms. Julie Armitage

Fax

856.692-8291

Bureau of Air Compliance

e.nia~

Jrocco@kimkon.com

Illinois Environmental Protection Agency

www.kimble.com

1021

North

Grand Ave.

P.O. Box19276

Springfield,

Illinois

62794-9276

—

-

---~ --

Re:

Kimble Glass,

Inc.

—

Chicago

Heights

CAAPP Permit No.

95090043

Application for Provisional Variance

Dear

Ms. Armitage:

Kimble

Glass,

Inc.

(‘Kimble”),

a

glass manufacturing

company,

hereby requests the Illinois Environmental Protection

Agency’s (‘IEPA’s”) recommendation

to the Pollution

Control

Board for an

gp~er~genpy

provi~i~nal

v~ariance

from select

requirements

of

the Title

V

Clean

Air

Act Permit

Program

(‘CAAPP

Permit’)

for

Kimbles

Uhicago

Heights facility

(‘Facility”).

Pursuant to Section 35 of the Illinois

Environmental Protection Act and its

implementing regulations, 35

III.

Adm.

Code

Sections

180.202(b) and

180.204, Kimble submits the following information

in

support of its request.

1.

Relief Requested

Kimble seeks a provisional variance from Condition 7.5.5(b) and certain limitations In Condition 7.5.6(a) of the Facility’s

CAAPP Permit No. 95090043.

Condition 7.5.5(b) requires operation of the electrostatic

precipitator (‘ESP”) at all times

during

the operation

of glass-melting

furnace

‘B” with

oxy-fuel

melter

(‘Furnace

B”).

Condition

7.5.6(a)

sets

forth

emissions

limitations for Furnace B,

as follows:

Nitrogen

Oxides

Particulate Matter

Sulfur Dioxide

(LbIHR)

(TIYr)

(Lb/HR)

(TIYr)

(Lb/HR)

(TIYr)

117.00

74.66

1.38

6.04

1.5

6.57

Kimble seeks the

provisional variance for a period of 72 hours.

2.

Description of Facility

Kimble manufactures

borosilicate glass containers for the pharmaceuiical industry.

The Facility occupies

roughly five

acres of land

at 1131 Arnold Street,

Chicago Heights,

in Cook

County, and is surrounded

by industrial facilities to the

north, south,

and

east and

by

multi-family housing

to

the

west.

The

Facility

has

been

in

operation

since

the

early

1900s.

3.

Description of Activity

For Which Variance is Souqht

At the Facility,

Kimble

operates

a single

glass

melting furnace,

Furnace

B,

which produces

vital

glassware

for the

company’s pharmaceutical clients.

Particulate emissions from Furnace

B are controlled by an electrostatic precipitator

(‘ESP’).

Specifically,

the

ESP,

manufactured by McGill

Airclean, employs

four electrically

charged

fields

to collect

particulate from

the furnace’s exhaust stream.

The ESP plays

an

integral

role in

Furnace B’s

compliance.

---

page 2

At present,

however, the

ESP for Furnace ‘B’ is not functioning

properly, and this situation is jeopardizing the Facility’s

ability

to comply

continuously with the Furnace

B particulate matter emissions

limitations.

This situation

is occuning

despite

the

fact

that

Kimble

has

maintained

the

ESP

in

accordance

with

a standard operating

and

maintenance

protocol

and

manufacturer’s

specifications.

In

fact,

during

November 2003,

Furnace

B’s ESP received

its

regularly

scheduled

cleaning,

performed by

the ESP

manufacturer

McGill

Airclean,

during

a

minor

rebricking of the furnace.

Following

the cleaning, the ESP was functioning

normally.

In

December 2004, two of the four fields on the ESP

began

having problems

maintaining

a sufficient

level of voltage

to maintain

optimal

collection efficiency.

Kimble

personnel

immediately

attempted

to remedy

this unforeseen

problem

using external

means

in

order to

forego

a

bypass

of the

ESP. Last week,

however, these fields shut down without warning and would

not restart.

Kirnble and

McGill Airclean

have come

to

the conclusion that something

inside the

unit likely is causing

the fields to be ‘shorted out.’

To perform

the necessary

repairs

and

maintenance,

Kimble

must

bypass

and

shut down

the

ESP.

To

the

best of

Kimble’s

knowledge,

the remaining two fields are maintaining compliance.

However,

optimal performance of the ESP as an air

pollution control device requires proper use of all four fields.

4.

Compliance Plan

Kimble believes that this

emergency internal

r~air

and-cleaning

will correct the situation and

restore the ESP to its full

capacity.

Accordingly,

the

Facility

plans

to

pertorm the following

steps.

First,

the ESP will be

shut down

to begin

cooling

the

unit.

Cooling

down

will

require

approximately 12

hours.

Once cooled,

the ESP

will

be

opened

and

all

collected

particulate

matter

that

remains

in

the

ESP

will

be

removed.

Following clean-up,

Kimble will conduct

an

inspection

of

the

ESP

interior

and

perform

the required

repairs.

The ESP

unit will then

be

dosed,

re-heated for

approximately five

to six hours,

and returned to service.

If additional

work is needed that cannot be completed within

this 72 hour period, Kimble

will contact IEPA to discuss the best manner of proceeding.

Kimble’s

Chicago Heights facility has not been

granted any other provisional

variances during this calendar year and

currently is

unaware of any other issues relating

to compliance with the Furnace

B particulate matter limits.

The entire

repair period for which

the provisional

variance

is requested will last no more than

72 hours.

5.

Materials

Used During Operation of Furnace

The

raw

materials

used

by

Furnace

B

during

glass

production

are

silica

sand,

borax

and salt,

nephalene

systenite,

boric

acid,

dolomite

lime,

potassium carbonate,

and

sodium chlorite.

None of

these raw materials is dassified

as

a

hazardous

air pollutant under the

Clean Air Act.

6.

Estimated Air

Emissions Resulting

From the Provisional Variance

Kimble

will

take several

measures

to

minimize

particulate

matter emissions

during

its

repair of the ESP.

First,

the

repair will occur

during

a

production

schedule

that

allows

for

reduced

input

by approximately 25 percent.

Second,

Kimble will increase its cullet input from its

current range of35 to 40 percent to approximately 50 percent, amounting to

a

nearly

10

percent increase

of cullet.

As

such,

the Company estimates

that particulate matter emissions during

this

72-hour repair period will

be 6.7 lbslhr, with

an estimate total emission of 482

lbs

Furnace

B

has an

annual particulate

matter

limit

of 6.04

tons per

year.

Based on

a typical

hourly emission

rate of

0.335

lbs/hr.,

the Facility’s

actual

annual

particulate

matter emissions

are

2,901.5

lb./year, or 1.45

tons/yr.,

which is

substantially

lower than

the Title V permit allowance.

Even ifthe maximumexpected particulate matter emissions were

generated

during the 72 hour repair period, total annual emissions

would still

fall significantly below the annual limit for

Furnace

B.

---

page 3

7.

Estimated Water

Emissions Resulting from the Provisional

Variance

Kimble

is not aware of any public water supplies that the

requested provisional

variance would

adverselyimpact.

8.

Assessment of Environmental

Impacts

Owing

to

the short time period

during

which

the

ESP

repair will

be

conducted, it

is

unlikely

that

any

exceedence

resulting

from

the provisional variance

will

cause

adverse environmental

effects.

As

indicated

above,

the

predicted

level of the exceedence for particulate matter is minimal.

9.

Failure to

Grant a Provisional Variance

Will Impose Arbitrary and

Unreasonable

Hardship

Kimble seeks a provisional variance that would exempt it from Condition

7.5.5(b), requiring continuous operation of the

ESP

while

Furnace

B

is

running,

and

Condition

7.5.6(a),

which contains

particulate

matter

emissions

limits, of its

CAAPP

Permit

Failure to

grant

an

emergency

provisional

variance

would

impose

an

arbitrary

and

unreasonable

hardship on

Kimble for the following two reasons.

First, frequent shutdowns cause

severe structural damage to glass

melting

furnaces

by over-cycling

the refractory brick,

leading

to

very

costly repairs

and

to

decreased

production.

Kimble

maintains a regular maintenancecycle for Furnace B and the ESP; requiring additional idling or shutdowns

in excess of

those already scheduled poses a significant risk that the structural integrity of the Furnace will be jeopardized.

Second,

the alternative option of continuing

to operate the Furnace while

the ESP

is being

repaired,

without

having received a

provisional variance, places Kimble in

a position of unreasonable and arbitrary hardship by leaving

it open to increased

enforcement risks for Title V

noncompliance.

Moreover,

as explained above,

the provisional

variance requested here

would last for only 72 hours

and would

produce only minimal excess emissions on

an annualized basis

because of the

extent of over-control

typically maintained at the Furnace.

*

*

*

In light of the facts set forth

above,

Kimble respectfully requests the IEPA’s

recommendation

that the Illinois

Pollution

Control

Board

grant

a

provisional

variance,

for

a period

of

72

hours,

from

Conditions 7.5.5(b)

and

7.5.6(a)

of the

Chicago

Heights facility’s

Title

V

Air Operating

Permit.

This letter

is submitted without any admission

of liability and

without any prejudice to any position

Kimble may take in regard to this or-any other matter.

We

would

be

happy to

discuss

this

matter

with

you

and

answer

any questions

you

may have.

Please feel

free

to

contact me at (856)

794-7125.

Ve

trulyyouf~)

/

James Rocco

Manager, Environmental Services